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Former Lake Ontario Ordnance Works Final Remedial Investigation Report for the OCCP April 2013 Appendix G Appendix G Data Usability Summary Report

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Page 1: Appendix G Data Usability Summary Report

Former Lake Ontario Ordnance Works

Final Remedial Investigation Report for the OCCP April 2013

Appendix G

Appendix G

Data Usability Summary Report

Page 2: Appendix G Data Usability Summary Report

MCGI

USEPA Region IIExplosives, Metals & Hexavalent Chromium

Data Validation Report

LOOWOccidental Property

TestAmerica Lab Report # C0H240416MCGI Project No. ER081001-4416

Prepared for:

Earth Resources Technology, Inc.Laurel, MD

Prepared by:“MCGI”

Meridian Consultant Group, Inc.Environmental Services & Data Validation

1997 Annapolis Exchange Pkwy, Suite 300Annapolis, MD 21401

Phone:(301)803-9207 Fax:(410)972-4701

www.meridiancgi.com

October 2010

Page 3: Appendix G Data Usability Summary Report

CONTENTS

C GLOSSARY OF ACRONYMS & TERMS

C COMMUNICATION RECORDS

C GLOSSARY OF DATA VALIDATION QUALIFIERS

C DATA VALIDATION REPORT NARRATIVE

C ELECTRONIC DATA DELIVERABLE (EDD) with applicable qualifiers, Refer to the EDD Excel file.

C SUPPORT DOCUMENTATION, Refer to the electronic Data Package PDF file.

Page 4: Appendix G Data Usability Summary Report

GLOSSARY OF ACRONYMS & TERMS

Page 5: Appendix G Data Usability Summary Report

GLOSSARY OF ACRONYMS & TERMS

One or more of the following acronyms and terms may have been used in the descriptive process of the OrganicData Validation.

Acronyms:BFB Bromofluorobenzene (volatile instrument performance check)BNA Base/Neutral/AcidCARD CLP Analytical Results DatabaseCCCs Calibration Check CompoundsCCS Contract Compliance ScreeningCF Calibration FactorCLP Contract Laboratory ProgramCOC Chain of CustodyCRQL Contract Required Quantitation LimitCSF Complete SDG File%D Percent DifferenceDAS Delivery of Analytical ServicesDCB Decachlorobiphenyl (Pesticide/PCB/ surrogate compound)DFTPP Decafluorotriphenylphosphine (semivolatile instrument performance check)DSF Data Summary FormECD Electron-Capture DetectorEICP Extended Ion Current ProfileEMSL-LV Environmental Monitoring Support Laboratory - Las VegasEPA United States Environmental Protection AgencyGC Gas ChromatographyGC/EC Gas Chromatography/Electron CaptureGC/MS Gas Chromatography/Mass SpectraGPC Gel Permeation Chromatography (Clean Up)ICAL Initial CalibrationIS Internal StandardLCS Laboratory Control SampleLCL Lower Control LimitMCL Maximum Contamination LevelMDL Method Detection LimitMS/MSD Matrix Spike/Matrix Spike Duplicatem/z The ratio of mass (m) to charge (z) of ions measured by GC/MSOADS Organic Analysis Data Sheet (Form 1)ORDA Organic Regional Data AssessmentPCB Poly Chlorinated BiphenylPEM Performance Evaluation MixturePRP Potential Responsible Party

-i-

Page 6: Appendix G Data Usability Summary Report

QA/QC Quality Assurance/Quality ControlQAPjP Quality Assurance Project PlanQC Quality Control%R Percent Recovery of spiked amountRAS Routine Analytical ServicesRF Response FactorRIC Reconstructed Ion ChromatogramRPD Relative Percent DifferenceRRF Relative Response FactorRSD Relative Standard DeviationRT Retention TimeRTW Retention Time WindowSDG Sample Delivery GroupSMC System Monitoring CompoundSMO Sample Management OfficeSOP Standard Operation ProceduresSOW Statement of WorkSPCCs System Performance Check CompoundsSSL Samples Shipping LogSVOA Semivolatile Organic AnalyteTCL Target Compound ListTCX Tetrachloro-m-Xylene (Pesticide/PCB surrogate compound)TIC Tentatively Identified CompoundTPH Total Petroleum HydrocarbonsTR Traffic ReportUCL Upper Control LimitVOA Volatile Organic AnalyteVTSR Validated Time of Sample Receipt

Terms:

Associated SamplesAny sample related to a particular QC analysis.

Case A finite, usually predetermined number of samples collected over a given time period for a particularsite. A Case consists of one or more Sample Delivery Group(s).

Contract Compliance Screening (CCS)A process in which the SMO inspects the data for contractual compliance and provides EMSL-LVlaboratories and the Regions with their findings.

-ii-

Page 7: Appendix G Data Usability Summary Report

Contractual Holding TimeThe time from VTSR (validated time of sample receipt) to laboratory extraction and /or analysis.

Data Validation Qualifier (DVQ)This refers to the column on the data summary form in which EPA Region III and other qualifiers have beenplaced by the data validator.

Data Validation Result (DVR)This refers to the column on the data summary form used to report results that have been modified by thedata validator. A result in the DVR column that is qualified “U” indicates a modification of the reportinglimit.

Field Blank Field blanks are intended to identify contaminants that may have been introduced in the field.Examples are rinsate blank (RB), field blanks (FB) and trip blank (TB).

Field DuplicateA duplicate sample generated in the field; not in the laboratory.

Initial Calibration (ICAL)The establishment of a calibration curve with the appropriate number of standards and concentrationranges. The calibration curve plots absorbances and/or emissions versus concentration of thestandards. .

Matrix Spike/Matrix Spike Duplicate (MS/MSD)Introduction of a known concentration of a compound into a sample to provide information aboutthe effect of sample matrix on the extraction and/or measurement methodology.

Performance Evaluation MixtureA standard used to verify that the ICAL sequence is stable throughout the GC or GC/MS analyses.

Sample Delivery Group (SDG)Defined by one of the following, whichever occurs first:- case of sample- each twenty field samples in a case or- each 14-day calendar period during which field samples in a case are received, beginning with thereceipt of the first sample in the SDG.

Technical Holding TimeThe time from sample collection to laboratory extraction and /or analysis

-iii-

Page 8: Appendix G Data Usability Summary Report

GLOSSARY OF ACRONYMS & TERMS

One or more of the following acronyms and terms may have been used in the descriptive process of the InorganicData Validation.

Acronyms:AA Atomic AbsorptionCARD CLP Analytical Results DatabaseCCB Continuing Calibration BlankCCS Contract Compliance ScreeningCCV Continuing Calibration VerificationCF Calibration FactorCLP Contract Laboratory ProgramCOC Chain of CustodyCRDL Contract Required Detection LimitCSF Complete SDG FileCV Cold Vapor%D Percent DifferenceDAS Delivery of Analytical ServicesDSF Data Summary FormEMSL-LV Environmental Monitoring Support Laboratory - Las VegasEPA United States Environmental Protection AgencyICAL Initial CalibrationICB Initial Calibration BlankICP Inductively Coupled PlasmaICS Interference Check SampleICV Initial Calibration VerificationIDL Instrument Detection LimitIRDA Inorganic Regional Data AssessmentLCS Laboratory Control SampleLCL Lower Control LimitMCL Maximum Contamination LevelMDC Minimum Detectable ConcentrationMDL Method Detection LimitMS/MSD Matrix Spike/Matrix Spike DuplicateMSA Method of Standard AdditionPB Preparation BlankPCB Poly Chlorinated BiphenylPRP Potential Responsible PartyQA/QC Quality Assurance/Quality ControlQAPjP Quality Assurance Project PlanQC Quality Control

-i-

Page 9: Appendix G Data Usability Summary Report

%R Percent Recovery of spiked amountRAS Routine Analytical ServicesRPD Relative Percent DifferenceRRF Relative Response FactorRSD Relative Standard DeviationSDG Sample Delivery GroupSMO Sample Management OfficeSOP Standard Operation ProceduresSOW Statement of WorkSSL Samples Shipping LogTAL Target Analyte ListTR Traffic ReportUCL Upper Control LimitVTSR Validated Time of Sample Receipt

Terms:

Associated SamplesAny sample related to a particular QC analysis. For Example: - For ICV, all samples run under the same calibration curve.- For duplicate RPD, all SDG samples digested/distilled of the same matrix.

Case A finite, usually predetermined number of samples collected over a given time period for a particularsite. A Case consists of one or more Sample Delivery Group(s).

Continuing Calibration Blank (CCB)A deionized water sample run every ten (10) samples designed to detect any carryovercontamination.

Continuing Calibration Verification (CCV)A deionized water sample run every ten (10) samples designed to detect any carryovercontamination.

Contract Compliance Screening (CCS)A process in which the SMO inspects the data for contractual compliance and provides EMSL-LVlaboratories and the Regions with their findings.

Contractual Holding TimeThe time from VTSR (validated time of sample receipt) to laboratory extraction and /or analysis.

-ii-

Page 10: Appendix G Data Usability Summary Report

Data Validation Qualifier (DVQ)This refers to the column on the data summary form in which EPA Region III and otherqualifiers have been placed by the data validator.

Data Validation Result (DVR)This refers to the column on the data summary form used to report results that have beenmodified by the data validator. A result in the DVR column that is qualified “U” indicatesa modification of the reporting limit.

Field Blank Field blanks are intended to identify contaminants that may have been introduced in the field.Examples are rinsate blank (RB), field blanks (FB) and trip blank (TB).

Field DuplicateA duplicate sample generated in the field; not in the laboratory.

Initial Calibration (ICAL)The establishment of a calibration curve with the appropriate number of standards and concentrationranges. The calibration curve plots absorbancies and/or emissions versus concentration of thestandards.

.Initial Calibration Blank (ICB)

First blank run after the calibration curve .

Initial Calibration Verification (ICV)First standard run after the calibration curve .

Matrix Spike/Matrix Spike Duplicate (MS/MSD)Introduction of a known concentration of a compound into a sample to provide information aboutthe effect of sample matrix on the extraction and/or measurement methodology.

Post Digestion SpikeThe addition of known amount of standard after digestion. (Also identified as analytical spike, orspike, for furnace analyses.)

Preparation Blank (PB)Blank taken through the digestion process to detect internal laboratory contamination.

-iii-

Page 11: Appendix G Data Usability Summary Report

Sample Delivery Group (SDG)Defined by one of the following, whichever occurs first:- case of sample- each twenty field samples in a case or- each 14-day calendar period during which field samples in a case are received, beginning with thereceipt of the first sample in the SDG.

Serial DilutionA sample run at a specific dilution to determine whether any significant chemical or physicalinterferences exist due to sample matrix effect, for ICP only.

Technical Holding Time

The time from sample collection to laboratory extraction and /or analysis.

-iv-

Page 12: Appendix G Data Usability Summary Report

COMMUNICATION RECORDS

Page 13: Appendix G Data Usability Summary Report

“N/A”

Page 14: Appendix G Data Usability Summary Report

GLOSSARY OF DATA VALIDATION QUALIFIERS

Page 15: Appendix G Data Usability Summary Report

GLOSSARY OF DATA QUALIFIER CODES (ORGANIC)

CODES RELATED TO IDENTIFICATION:(Confidence concerning presence or absence of compounds)

U = Not detected above the level of the associated value. The associated value is eitherthe approximate sample quantitation or detection limit.

NO CODE = Confirmed identification

B = Not detected substantially above the level reported in laboratory or field blanks.

R = Unusable results. Analyte may or may not be present in the sample.

N = Tentative identification. Consider present. Special methods may be needed toconfirm its presence or absence in future sampling efforts.

CODES RELATED TO QUANTITATION:(Can be used for both positive results and sample quantitation limits)

J = Analyte present. Reported value may not be accurate or precise (estimated value).

K = Analyte present. Reported value may be biased high. Actual value is expected to belower.

L = Analyte present. Reported value may be biased low. Actual value is expected to behigher.

UJ = Not detected. Quantitation limit may be inaccurate or imprecise.

UL = Not detected. Quantitation limit is probably higher.

OTHER CODES:

NJ = Qualitative identification questionable. Presumptively present at approximatequantity.

Q = No analytical result.

X =Data not Validated.

Page 16: Appendix G Data Usability Summary Report

GLOSSARY OF DATA QUALIFIER CODES (INORGANIC)

CODES RELATED TO IDENTIFICATION:(Confidence concerning presence or absence of analytes).

U = Not detected above the level of the associated value. The associated value is eitherthe approximate sample quantitation or detection limit.

NO CODE = Confirmed identification

B = Not detected substantially above the level reported in laboratory or field blanks.

R = Unusable results. Analyte may or may not be present in the sample.

N = Tentative identification. Consider present. Special methods may be needed toconfirm its presence or absence in future sampling efforts.

CODES RELATED TO QUANTITATION:(Can be used for both positive results and sample detection limits)

J = Analyte present. Reported value may not be accurate or precise (estimated value).

K = Analyte present. Reported value may be biased high. Actual value is expected to belower.

L = Analyte present. Reported value may be biased low. Actual value is expected to behigher.

UJ = Not detected. Quantitation limit may be inaccurate or impresice.

UL = Not detected. Quantitation limit is probably higher.

OTHER CODES:

NJ = Qualitative identification questionable. Presumptively present at approximatequantity.

Q = No analytical Result.X = Data not validated.

Page 17: Appendix G Data Usability Summary Report

DATA VALIDATION REPORT NARRATIVE

Page 18: Appendix G Data Usability Summary Report

USEPA Region II Data ValidationLOOWMCGI/ER081001-4416.wpd Page 5 of 12

.MCGI

Meridian Consultant Group, Inc. (301)803-9207 Phone

Environmental Services & Data Validation (410)972-4701 Fax

1997 Annapolis Exchange Pkwy., Suite 300 www.meridiancgi.com Annapolis, MD 21401

DATE: October 14, 2010

SUBJECT: USEPA Region II Organic & Inorganic Data Validation ReportExplosives, Metals & Hexavalent ChromiumTestAmerica Lab SDG No. C0H240416Site: LOOW, Occidental PropertyMSTI Project No. ER081001-4416

FROM:

Meridian Consultant Group, Inc.

TO:Earth Resources Technology, Inc.

OVERVIEW

This Sample Delivery Group (SDG) consisted of seventeen (17) soil samples submitted to TestAmericaLaboratories, Pittsburgh, PA, for Explosives, Metals & Hexavalent Chromium analyses according to SW-846,Method 8330, 6020A & 7196A, respectively. The Explosives and Metals analyses were subcontracted toTestAmerica, St. Louis Laboratory. The sample set included one (1) soil field duplicate pair. The samples wereanalyzed in accordance with the Chain-of-Custody (COC), see Sample Identification Summary.

Sample Identification Summary

SAMPLE INFORMATION Analysis

Field ID Lab ID Matrix X M Cr

C2-OXY-SO-PW-0.5 C0H240416001 Soil x x xC2-OXY-SO-PW-1.0 C0H240416002 Soil x x xC2-OXY-SO-PE-0.5 C0H240416003 Soil x x xC2-OXY-SO-PE-1 C0H240416004 Soil x x xC2-OXY-SO-PN-05 C0H240416005 Soil x x xC2-OXY-SO-PN-1 C0H240416006 Soil x x xC2-OXY-SO-PS-0.5 C0H240416007 Soil x x xC2-OXY-SO-PS-1 C0H240416008 Soil x x x

Page 19: Appendix G Data Usability Summary Report

SAMPLE INFORMATION Analysis

Field ID Lab ID Matrix X M Cr

USEPA Region II Data ValidationLOOWMCGI/ER081001-4416.wpd Page 6 of 12

C2-OXY-SO-DUP1 C0H240416009 Soil x x xC2-OXY-HN-0.5 C0H240416010 Soil x x xC2-OXY-HN-1 C0H240416011 Soil x x xC2-OXY-HS-0.5 C0H240416012 Soil x x xC2-OXY-HS-1 C0H240416013 Soil x x xC2-OXY-HE-0.5 C0H240416014 Soil x x xC2-OXY-HE-1 C0H240416015 Soil x x xC2-OXY-HW-0.5 C0H240416016 Soil x x xC2-OXY-HW-1 C0H240416017 Aqueous x x x X=Explosives. M=Metals, Cr=Hexavalent Chromium

The Organic analytical results were validated according to the pertinent parts of U.S. Environmental ProtectionAgency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelines for Organic Data Review(October 1999), with Modifications for use within USEPA Region II according to USEPA Region II SOP No.HW-16, Revision 2, September 2006: Nitroaromatics and Nitroamines by HPLC (USEPA, 2006c); along withthe Quality Assurance/Quality Control (QA/QC) requirements for the analytical methods used for the analyses.

The Inorganic analytical results were validated according to the pertinent parts of U.S. Environmental ProtectionAgency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelines for Inorganic DataReview (July 2002), with Modifications for use within USEPA Region II according to USEPA Region II SOPNo. HW-2, Revision 13, September 2006, Evaluation of Metals Data for the CLP Program (USEPA, 2006b);along with the Quality Assurance/Quality Control (QA/QC) requirements for the analytical methods used forthe analyses.

Please note that the “B” qualifier was used instead of the “U” qualifier, as per USEPA Region II, to point outclearly those compounds qualified due to blank contamination.

Page 20: Appendix G Data Usability Summary Report

USEPA Region II Data ValidationLOOWMCGI/ER081001-4416.wpd Page 7 of 12

“ORGANIC VALIDATION”

The validation was based on the following parameters:

Data Validation Summary

ParametersX

q t a

* Data Completeness 17 0

* Holding Time 17 0

* Calibrations 17 0

* Laboratory and Field Blanks analyses 17 0

* Surrogate Recoveries 17 0

* Matrix Spike/Matrix Spike Duplicate 17 0

* Laboratory Control Sample(LCS) 17 0

* Laboratory and/or Field Duplicates 17 0

* Internal Standards 17 0

* Pesticide Instrument Performance 17 0

* Sample Cleanup 17 0

Compound Identification x 17 10

Compound Quantitation x 17 11

* Sample Preservation 17 0

* All Criteria were met for that Parameter, X=Explosives

q=qualified; t=total number of samples analyzed; a=number of samples affected

SUMMARY

All samples were successfully analyzed for all target compounds according to U.S. Environmental ProtectionAgency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelines for Organic Data Review(October 1999), with Modifications for use within USEPA Region II; along with the QualityAssurance/Quality Control (QA/QC) requirements for the analytical methods used for the analyses. Allinstruments and method sensitivities were according to the specified analytical methods. Refer to MinorProblems for information regarding biases identified during data validation.

MAJOR PROBLEMS

MINOR PROBLEMS

Page 21: Appendix G Data Usability Summary Report

USEPA Region II Data ValidationLOOWMCGI/ER081001-4416.wpd Page 8 of 12

NOTES

C Electronic Data Deliverable (EDD): Several rows in an electronic data deliverable (EDD) are markedwith an “X” and hidden before printing a data summary form. These rows may include quality controlsamples such as Method Blanks, Laboratory Control Samples, Matrix Spikes, or Matrix SpikeDuplicates which are not validated. Additionally, some field sample results may not be used since onlyone (1) result for each compound is reported after validation. The following list indicates someinstances in which an “X” may be placed in the DVQ column:1. The compounds in an analysis that have exceeded the instrument calibration range.2. All compounds in a diluted analysis that were within the calibration range in the initial analysis.3. All compounds in either the initial analysis or re-analysis of a sample, depending on which

analysis is not reported on the EDD.Although QC samples and some field samples results may not be used, all data were reviewed andconsidered in the overall assessment.

C Data Validation Qualifier (DVQ): This refers to the column on the data summary form in which EPARegion III and other qualifiers have been placed by the data validator.

C Data Validation Result (DVR): This refers to the column on the data summary form used to reportresults that have been modified by the data validator. A result in the DVR column that is qualified “U”indicates a modification of the reporting limit. Results in the DVR column supersede those reported bythe laboratory.

C Tentatively Identified Compounds (TICs): The TICs, if applicable, were reviewed during datavalidation.

C Compound Quantitation: Positive results for compounds which are below the CRQL were qualifiedas estimated “J” on the EDD.

C Blank Contaminants: The maximum concentration of all compounds found in the analyses of the trip,field or laboratory method blanks are listed in the following table. Associated samples with positiveresults of common laboratory contaminants less than ten times (<10X) the blank concentration, orpositive results of other contaminants less than five times (<5X) the blank concentration, found in theassociated samples were qualified as “B” on the EDDs.

AnalyticalFraction

Compound MaximumConcentration

Units Blank Type

Explosives None*Common lab contaminant

Page 22: Appendix G Data Usability Summary Report

USEPA Region II Data ValidationLOOWMCGI/ER081001-4416.wpd Page 9 of 12

C Retention Time (RT): The retention time on the confirmation column for 1,3-Dinitrobenzene, 2-Amino-4,6-dinitrotolune and 3 Nitrotoluene were shifted outside the RT window. These compoundswere confirmed by spectral identification. No action was taken.

C Calibration: One or more compound(s) failed the percent difference (%D) precision criteria in thecontinuing calibration dated May 28, 2010. No data were affected.

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The MS/MSD displayed five (5) out of twenty-eight (28) spike recoveries above the QC limit due to high concentration in the native sample. No actionwas taken.

Page 23: Appendix G Data Usability Summary Report

USEPA Region II Data ValidationLOOWMCGI/ER081001-4416.wpd Page 10 of 12

“INORGANIC VALIDATION”

The validation was based on the following parameters:

Data Validation Summary

ParametersM Cr+6

q t a q t a* Data Completeness 17 0 17 0

* Holding Time 17 0 17 0

* Calibration Verification 17 0 17 0

* Laboratory and Field Blanks analyses 17 0 17 0

* ICP Interference Check Sample results 17 0 17 0

Matrix Spike recoveries (MS) x 17 17 x 17 17

Laboratory and Field Duplicates 17 0 x 17 1

x Laboratory Control Sample(LCS) 17 0 17 0

Serial Dilution results x 17 17 17 0

* Furnace Atomic Absorption results (FAA) 17 0 17 0

* Analyte Identification 17 0 17 0

* Analyte Quantitation 17 0 17 0* All Criteria were met for that Parameter, M=Metals, Cr+6=Hexavalent Chromium

q=qualified; t=total number of samples analyzed; a=number of samples affected

SUMMARY

All samples were successfully analyzed for all target analytes according to the pertinent parts of U.S.Environmental Protection Agency (USEPA) Contract Laboratory Program (CLP) National FunctionalGuidelines for Inorganic Data Review (July 2002), with Modifications for use within USEPA Region II; alongwith the Quality Assurance/Quality Control (QA/QC) requirements for the analytical methods used for theanalyses. All instruments and method sensitivities were according to the analytical methods. Refer to MinorProblems for information regarding biases identified during data validation.

MAJOR ISSUES

C None noted.

MINOR ISSUES

C Laboratory and Field Blanks analyses: Analytes detected in the laboratory and/or equipment blanks,that affect sample results, with concentration above the instrument detection limit (IDL) are listedbelow. Analytes in the samples with concentration less than five (5) times the blank concentration havebeen reported on the EDDs and qualified “B”.

Page 24: Appendix G Data Usability Summary Report

USEPA Region II Data ValidationLOOWMCGI/ER081001-4416.wpd Page 11 of 12

Analyte Blank TypeNone

PB = Preparation BlankICB = Initial Calibration BlankCCB = Continuing Calibration Blank RB = Rinse Blank

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The soil MS/MSD displayed low recoveries (i.e.,<75%, but >30%) for Sb analyte. Positive results and quantitation limits maybe biased low and werequalified “J” & “UJ”, respectively.

The soil MS/MSD displayed high recoveries (i.e., >125%) for Cr & Ni analytes. Positive results maybebiased high and were qualified “J”.

C Serial Dilution: The Zn analyte displayed a percent difference (%D) greater than 10% in the soilsamples. Positive results may be estimated and were qualified “J”.

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The Hexavalent Chromium MS/MSD displayedlow recoveries outside the QC limits. The samples were redigested and reanalyzed with similar resultsfor the MS/MSD. Positive results and quantitation limits maybe biased low and were qualified “J” &“UJ”, respectively.

C Duplicate Analysis: The Hexavalent Chromium duplicate analysis of sample C2-OXY-HE-1 resultedin an RPD outside the QC limit. Positive result for this sample was qualified “J”

NOTES

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The soil MS/MSD recoveries displayed recoveriesoutside the QC limits for Al, Ba, Ca, Cu, Fe, Pb, Mg, Mn & Zn analytes. However, the sampleconcentration for these analytes were greater than 4x the spike concentration. No action was taken.

Page 25: Appendix G Data Usability Summary Report

USEPA Region II Data ValidationLOOWMCGI/ER081001-4416.wpd Page 12 of 12

REPORT CONTENT STATEMENT

All data for this project were reviewed in accordance with the pertinent parts of the U.S. EnvironmentalProtection Agency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelines for OrganicData Review (October 1999) and for Inorganic Data Review (July 2002), with Modifications for use withinUSEPA Region II; along with the Quality Assurance/Quality Control (QA/QC) requirements for the analyticalmethods used for the analyses. The text of the report addresses only those problems affecting data usability.

ATTACHMENTS

l ) Glossary of Data Qualifiers2) Electronic Data Deliverable (EDD). These include:

(a) All results for target compounds with qualifier codes where applicable.(b) All unusable detection limits (qualified “R”), where applicable.

3) Electronic Data Package (.pdf file) as Support Documentation

DCN: ER081001-4416

Respectfully Submitted,

Date: October 14, 2010

QA/Review:

Page 26: Appendix G Data Usability Summary Report

MCGI

USEPA Region IIVolatiles, Semivolatiles, PCBs, Explosives, Metals & Hexavalent Chromium

Data Validation Report

LOOWLewPort School Property

TestAmerica Lab Report # C0H250642MCGI Project No. ER081001-5642

Prepared for:

Earth Resources Technology, Inc.Laurel, MD

Prepared by:“MCGI”

Meridian Consultant Group, Inc.Environmental Services & Data Validation

1997 Annapolis Exchange Pkwy, Suite 300Annapolis, MD 21401

Phone:(301)803-9207 Fax:(410)972-4701

www.meridiancgi.com

October 2010

Page 27: Appendix G Data Usability Summary Report

CONTENTS

C GLOSSARY OF ACRONYMS & TERMS

C COMMUNICATION RECORDS

C GLOSSARY OF DATA VALIDATION QUALIFIERS

C DATA VALIDATION REPORT NARRATIVE

C ELECTRONIC DATA DELIVERABLE (EDD) with applicable qualifiers, Refer to the EDDExcel file.

C SUPPORT DOCUMENTATION, Refer to the electronic Data Package PDF file.

Page 28: Appendix G Data Usability Summary Report

GLOSSARY OF ACRONYMS & TERMS

Page 29: Appendix G Data Usability Summary Report

GLOSSARY OF ACRONYMS & TERMS

One or more of the following acronyms and terms may have been used in the descriptiveprocess of the Organic Data Validation.

Acronyms:BFB Bromofluorobenzene (volatile instrument performance check)BNA Base/Neutral/AcidCARD CLP Analytical Results DatabaseCCCs Calibration Check CompoundsCCS Contract Compliance ScreeningCF Calibration FactorCLP Contract Laboratory ProgramCOC Chain of CustodyCRQL Contract Required Quantitation LimitCSF Complete SDG File%D Percent DifferenceDAS Delivery of Analytical ServicesDCB Decachlorobiphenyl (Pesticide/PCB/ surrogate compound)DFTPP Decafluorotriphenylphosphine (semivolatile instrument performance check)DSF Data Summary FormECD Electron-Capture DetectorEICP Extended Ion Current ProfileEMSL-LV Environmental Monitoring Support Laboratory - Las VegasEPA United States Environmental Protection AgencyGC Gas ChromatographyGC/EC Gas Chromatography/Electron CaptureGC/MS Gas Chromatography/Mass SpectraGPC Gel Permeation Chromatography (Clean Up)ICAL Initial CalibrationIS Internal StandardLCS Laboratory Control SampleLCL Lower Control LimitMCL Maximum Contamination LevelMDL Method Detection LimitMS/MSD Matrix Spike/Matrix Spike Duplicatem/z The ratio of mass (m) to charge (z) of ions measured by GC/MSOADS Organic Analysis Data Sheet (Form 1)ORDA Organic Regional Data AssessmentPCB Poly Chlorinated BiphenylPEM Performance Evaluation MixturePRP Potential Responsible Party

-i-

Page 30: Appendix G Data Usability Summary Report

QA/QC Quality Assurance/Quality ControlQAPjP Quality Assurance Project PlanQC Quality Control%R Percent Recovery of spiked amountRAS Routine Analytical ServicesRF Response FactorRIC Reconstructed Ion ChromatogramRPD Relative Percent DifferenceRRF Relative Response FactorRSD Relative Standard DeviationRT Retention TimeRTW Retention Time WindowSDG Sample Delivery GroupSMC System Monitoring CompoundSMO Sample Management OfficeSOP Standard Operation ProceduresSOW Statement of WorkSPCCs System Performance Check CompoundsSSL Samples Shipping LogSVOA Semivolatile Organic AnalyteTCL Target Compound ListTCX Tetrachloro-m-Xylene (Pesticide/PCB surrogate compound)TIC Tentatively Identified CompoundTPH Total Petroleum HydrocarbonsTR Traffic ReportUCL Upper Control LimitVOA Volatile Organic AnalyteVTSR Validated Time of Sample Receipt

Terms:

Associated SamplesAny sample related to a particular QC analysis.

Case A finite, usually predetermined number of samples collected over a given timeperiod for a particular site. A Case consists of one or more Sample DeliveryGroup(s).

Contract Compliance Screening (CCS)A process in which the SMO inspects the data for contractual compliance andprovides EMSL-LV laboratories and the Regions with their findings.

-ii-

Page 31: Appendix G Data Usability Summary Report

Contractual Holding TimeThe time from VTSR (validated time of sample receipt) to laboratoryextraction and /or analysis.

Data Validation Qualifier (DVQ)This refers to the column on the data summary form in which EPA Region III andother qualifiers have been placed by the data validator.

Data Validation Result (DVR)This refers to the column on the data summary form used to report results that havebeen modified by the data validator. A result in the DVR column that is qualified“U” indicates a modification of the reporting limit.

Field Blank Field blanks are intended to identify contaminants that may have beenintroduced in the field. Examples are rinsate blank (RB), field blanks (FB) andtrip blank (TB).

Field DuplicateA duplicate sample generated in the field; not in the laboratory.

Initial Calibration (ICAL)The establishment of a calibration curve with the appropriate number ofstandards and concentration ranges. The calibration curve plots absorbancesand/or emissions versus concentration of the standards. .

Matrix Spike/Matrix Spike Duplicate (MS/MSD)Introduction of a known concentration of a compound into a sample to provideinformation about the effect of sample matrix on the extraction and/ormeasurement methodology.

Performance Evaluation MixtureA standard used to verify that the ICAL sequence is stable throughout the GCor GC/MS analyses.

Sample Delivery Group (SDG)Defined by one of the following, whichever occurs first:- case of sample- each twenty field samples in a case or- each 14-day calendar period during which field samples in a case arereceived, beginning with the receipt of the first sample in the SDG.

Technical Holding TimeThe time from sample collection to laboratory extraction and /or analysis

-iii-

Page 32: Appendix G Data Usability Summary Report

GLOSSARY OF ACRONYMS & TERMS

One or more of the following acronyms and terms may have been used in the descriptiveprocess of the Inorganic Data Validation.

Acronyms:AA Atomic AbsorptionCARD CLP Analytical Results DatabaseCCB Continuing Calibration BlankCCS Contract Compliance ScreeningCCV Continuing Calibration VerificationCF Calibration FactorCLP Contract Laboratory ProgramCOC Chain of CustodyCRDL Contract Required Detection LimitCSF Complete SDG FileCV Cold Vapor%D Percent DifferenceDAS Delivery of Analytical ServicesDSF Data Summary FormEMSL-LV Environmental Monitoring Support Laboratory - Las VegasEPA United States Environmental Protection AgencyICAL Initial CalibrationICB Initial Calibration BlankICP Inductively Coupled PlasmaICS Interference Check SampleICV Initial Calibration VerificationIDL Instrument Detection LimitIRDA Inorganic Regional Data AssessmentLCS Laboratory Control SampleLCL Lower Control LimitMCL Maximum Contamination LevelMDC Minimum Detectable ConcentrationMDL Method Detection LimitMS/MSD Matrix Spike/Matrix Spike DuplicateMSA Method of Standard AdditionPB Preparation BlankPCB Poly Chlorinated BiphenylPRP Potential Responsible PartyQA/QC Quality Assurance/Quality ControlQAPjP Quality Assurance Project PlanQC Quality Control

-i-

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%R Percent Recovery of spiked amountRAS Routine Analytical ServicesRPD Relative Percent DifferenceRRF Relative Response FactorRSD Relative Standard DeviationSDG Sample Delivery GroupSMO Sample Management OfficeSOP Standard Operation ProceduresSOW Statement of WorkSSL Samples Shipping LogTAL Target Analyte ListTR Traffic ReportUCL Upper Control LimitVTSR Validated Time of Sample Receipt

Terms:

Associated SamplesAny sample related to a particular QC analysis. For Example: - For ICV, all samples run under the same calibration curve.- For duplicate RPD, all SDG samples digested/distilled of the same matrix.

Case A finite, usually predetermined number of samples collected over a given timeperiod for a particular site. A Case consists of one or more Sample DeliveryGroup(s).

Continuing Calibration Blank (CCB)A deionized water sample run every ten (10) samples designed to detect anycarryover contamination.

Continuing Calibration Verification (CCV)A deionized water sample run every ten (10) samples designed to detect anycarryover contamination.

Contract Compliance Screening (CCS)A process in which the SMO inspects the data for contractual compliance andprovides EMSL-LV laboratories and the Regions with their findings.

Contractual Holding TimeThe time from VTSR (validated time of sample receipt) to laboratoryextraction and /or analysis.

-ii-

Page 34: Appendix G Data Usability Summary Report

Data Validation Qualifier (DVQ)This refers to the column on the data summary form in which EPARegion III and other qualifiers have been placed by the data validator.

Data Validation Result (DVR)This refers to the column on the data summary form used to reportresults that have been modified by the data validator. A result in theDVR column that is qualified “U” indicates a modification of thereporting limit.

Field Blank Field blanks are intended to identify contaminants that may have beenintroduced in the field. Examples are rinsate blank (RB), field blanks (FB) andtrip blank (TB).

Field DuplicateA duplicate sample generated in the field; not in the laboratory.

Initial Calibration (ICAL)The establishment of a calibration curve with the appropriate number ofstandards and concentration ranges. The calibration curve plots absorbanciesand/or emissions versus concentration of the standards.

.Initial Calibration Blank (ICB)

First blank run after the calibration curve .

Initial Calibration Verification (ICV)First standard run after the calibration curve .

Matrix Spike/Matrix Spike Duplicate (MS/MSD)Introduction of a known concentration of a compound into a sample to provideinformation about the effect of sample matrix on the extraction and/ormeasurement methodology.

Post Digestion SpikeThe addition of known amount of standard after digestion. (Also identified asanalytical spike, or spike, for furnace analyses.)

Preparation Blank (PB)Blank taken through the digestion process to detect internal laboratorycontamination.

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Sample Delivery Group (SDG)Defined by one of the following, whichever occurs first:- case of sample- each twenty field samples in a case or- each 14-day calendar period during which field samples in a case arereceived, beginning with the receipt of the first sample in the SDG.

Serial DilutionA sample run at a specific dilution to determine whether any significantchemical or physical interferences exist due to sample matrix effect, for ICPonly.

Technical Holding Time

The time from sample collection to laboratory extraction and /or analysis.

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Page 36: Appendix G Data Usability Summary Report

COMMUNICATION RECORDS

Page 37: Appendix G Data Usability Summary Report

Subject: RE: LOOW, LewPort School Property DV EDDs/Reports

From:< > (Remove Preferred Sender)

Date: Wed, Oct 20, 2010 11:51 amTo:

Cr+6 should have been reported for all of the Oxy samples only. For LewPort samples, totalchromium was all that was required. COCs for LewPort samples were incorrectly marked forCr+6 analysis. The lab was notified of this change post-COC submittal.

From: .Sent: Wednesday, October 20, 2010 11:48 AMTo: Subject: RE: LOOW, LewPort School Property DV EDDs/Reports

Yes Mike, I just have to modify it by inserting a note in each report to indicate that the Cr+6analyses for the soil samples on the COCs associated with those 3 SDGs were canceled. I'llneed an e-mail from you indicating that clearly please, because I'll insert a copy of the e-mail inthe reports as documentation.

Should you have any question or need further information, please do not hesitate to call me @

Best Regards,

Meridian Consultant Group, Inc. (MCGI)1997 Annapolis Exchange Pkwy, Suite 300Annapolis, MD 21401

Page 38: Appendix G Data Usability Summary Report

GLOSSARY OF DATA VALIDATION QUALIFIERS

Page 39: Appendix G Data Usability Summary Report

GLOSSARY OF DATA QUALIFIER CODES (ORGANIC)

CODES RELATED TO IDENTIFICATION:(Confidence concerning presence or absence of compounds)

U = Not detected above the level of the associated value. Theassociated value is either the approximate sample quantitationor detection limit.

NO CODE = Confirmed identification

B = Not detected substantially above the level reported inlaboratory or field blanks.

R = Unusable results. Analyte may or may not be present in thesample.

N = Tentative identification. Consider present. Special methodsmay be needed to confirm its presence or absence in futuresampling efforts.

CODES RELATED TO QUANTITATION:(Can be used for both positive results and sample quantitation limits)

J = Analyte present. Reported value may not be accurate orprecise (estimated value).

K = Analyte present. Reported value may be biased high. Actualvalue is expected to be lower.

L = Analyte present. Reported value may be biased low. Actualvalue is expected to be higher.

UJ = Not detected. Quantitation limit may be inaccurate orimprecise.

UL = Not detected. Quantitation limit is probably higher.

OTHER CODES:

NJ = Qualitative identification questionable. Presumptively presentat approximate quantity.

Q = No analytical result.

X =Data not Validated.

Page 40: Appendix G Data Usability Summary Report

GLOSSARY OF DATA QUALIFIER CODES (INORGANIC)

CODES RELATED TO IDENTIFICATION:(Confidence concerning presence or absence of analytes).

U = Not detected above the level of the associated value. Theassociated value is either the approximate sample quantitationor detection limit.

NO CODE = Confirmed identification

B = Not detected substantially above the level reported inlaboratory or field blanks.

R = Unusable results. Analyte may or may not be present in thesample.

N = Tentative identification. Consider present. Special methodsmay be needed to confirm its presence or absence in futuresampling efforts.

CODES RELATED TO QUANTITATION:(Can be used for both positive results and sample detection limits)

J = Analyte present. Reported value may not be accurate orprecise (estimated value).

K = Analyte present. Reported value may be biased high. Actualvalue is expected to be lower.

L = Analyte present. Reported value may be biased low. Actualvalue is expected to be higher.

UJ = Not detected. Quantitation limit may be inaccurate orimpresice.

UL = Not detected. Quantitation limit is probably higher.

OTHER CODES:

NJ = Qualitative identification questionable. Presumptively presentat approximate quantity.

Q = No analytical Result.X = Data not validated.

Page 41: Appendix G Data Usability Summary Report

DATA VALIDATION REPORT NARRATIVE

Page 42: Appendix G Data Usability Summary Report

USEPA Region II Data ValidationLOOWMCGI/ER081001-6496.wpd Page 5 of 12

.MCGI

Meridian Consultant Group, Inc. (301)803-9207 Phone

Environmental Services & Data Validation (410)972-4701 Fax

1997 Annapolis Exchange Pkwy., Suite 300 www.meridiancgi.com Annapolis, MD 21401

DATE: October 09, 2010

SUBJECT: USEPA Region II Organic & Inorganic Data Validation ReportVolatiles, Semivolatiles, PCBs, Explosives, Metals & Hexavalent ChromiumTestAmerica Lab SDG No. C0H260496Site: LOOW, LewPort School PropertyMSTI Project No. ER081001-6496

FROM:

Meridian Consultant Group, Inc.

TO:Earth Resources Technology, Inc.

OVERVIEW

This Sample Delivery Group (SDG) consisted of thirteen (13) soil & four (4) aqueous samplessubmitted to TestAmerica Laboratories, Pittsburgh, PA, for Volatiles, Semivolaties, PCBs,Explosives, Metals & Hexavalent Chromium analyses according to SW-846, Method 8260B, 8270C,8082, 8330, 6020A & 7196A, respectively. The Explosives and the Metals analyses weresubcontracted to TestAmerica, St. Louis Laboratory. The sample set included one (1) trip blank,analyzed for volatiles only, one (1) rinsate blank, and one (1) soil & one (1) aqueous field duplicatepairs. The samples were analyzed in accordance with the Chain-of-Custody (COC), see SampleIdentification Summary.

Sample Identification Summary

SAMPLE INFORMATION Analysis

Field ID Lab ID Matrix V S P X M Cr

C2-LPCSD-SO-A01-0.5 C0H260496001 Soil x x x x xC2-LPCSD-SO-A01-4 C0H260496002 Soil x x x x xC2-LPCSD-SO-A01-4-DUP C0H260496003 Soil x x x x xC2-LPCSD-SO-A10-0.5 C0H260496004 Soil x x x x xC2-LPCSD-SO-A10-3 C0H260496005 Soil x x x x x

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SAMPLE INFORMATION Analysis

Field ID Lab ID Matrix V S P X M Cr

USEPA Region II Data ValidationLOOWMCGI/ER081001-6496.wpd Page 6 of 12

C2-LPCSD-SO-A10A-0.5 C0H260496006 Soil x x x x xC2-LPCSD-SO-A10A-4 C0H260496007 Soil x x x x xC2-LPCSD-SO-A09-0.5 C0H260496008 Soil x x x x xC2-LPCSD-SO-A09-4 C0H260496009 Soil x x x x xC2-OXY-SO-S02-7 C0H260496010 Soil x xC2-SWDD-SW-01 C0H260496011 Aqueous x x x x xC2-SWDD-SW-01-DUP C0H260496012 Aqueous x x x x xC2-SWDD-SO-01-1 C0H260496013 Soil x x x x xC2-SWDD-SO-01-1-DUP C0H260496014 Soil x x x x xC2-SWDD-SO-01-3 C0H260496015 Soil x x x x xTRIP BLANK C0H260496016 Aqueous xC2-LPCSD-RB1 C0H260496017 Aqueous x x x x x x

V=Volatiles, S=Semivolatiles, P=PCBs, X=Explosives. M=Metals, Cr=Hexavalent Chromium

The Organic analytical results were validated according to the pertinent parts of U.S. EnvironmentalProtection Agency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelinesfor Organic Data Review (October 1999), with Modifications for use within USEPA Region IIaccording to USEPA Region II SOP HW-24, Revision 2, August 2008: Validating Volatile OrganicCompounds by SW-846 Method 8260B (USEPA, 2008), USEPA Region II SOP No. HW-22,Revision 4, August 2009: Validating Semivolatile Organic Compounds by SW846 Method 8270(USEPA, 2009), USEPA Region II SOP No. HW-45, Revision 1, October 2006: Data ValidationSOP of Organic Analysis of PCBs by Gas Chromatography SW-846 Method 8082A (USEPA,2006d), and USEPA Region II SOP No. HW-16, Revision 2, September 2006: Nitroaromatics andNitroamines by HPLC (USEPA, 2006c); along with the Quality Assurance/Quality Control(QA/QC) requirements for the analytical methods used for the analyses.

The Inorganic analytical results were validated according to the pertinent parts of U.S.Environmental Protection Agency (USEPA) Contract Laboratory Program (CLP) NationalFunctional Guidelines for Inorganic Data Review (July 2002), with Modifications for use withinUSEPA Region II according to USEPA Region II SOP No. HW-2, Revision 13, September 2006,Evaluation of Metals Data for the CLP Program (USEPA, 2006b); along with the QualityAssurance/Quality Control (QA/QC) requirements for the analytical methods used for the analyses.

Please note that the “B” qualifier was used instead of the “U” qualifier, as per USEPA Region II,to point out clearly those compounds qualified due to blank contamination.

Forteen soil/aqueous samples were marked on the CoC for Hexavalent Chromium analysis. Theanalysis of these sample for this analyte were canceled as per ERT, Inc request. See communicationrecords.

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USEPA Region II Data ValidationLOOWMCGI/ER081001-6496.wpd Page 7 of 12

“ORGANIC VALIDATION”

The validation was based on the following parameters:

Data Validation Summary

ParametersV S P X

q t a q t a q t a q t a

* Data Completeness 16 0 15 0 15 0 15 0

* Holding Time 16 0 15 0 15 0 15 0

* Calibrations 16 0 15 0 15 0 15 0

Laboratory and Field Blanks analyses x 16 5 15 0 15 0 15 0

* Surrogate Recoveries 16 0 15 0 15 0 15 0

* Matrix Spike/Matrix Spike Duplicate 16 0 15 0 15 0 15 0

* Laboratory Control Sample(LCS) 16 0 15 0 15 0 15 0

* Laboratory and/or Field Duplicates 16 0 15 0 15 0 15 0

* Internal Standards 16 0 15 0 15 0 15 0

* Pesticide Instrument Performance 16 0 15 0 15 0 15 0

* Sample Cleanup 16 0 15 0 15 0 15 0

* Compound Identification 16 0 15 0 15 0 15 0

Compound Quantitation 16 0 15 0 x 15 2 15 0

* Sample Preservation 16 0 15 0 15 0 15 0

* All Criteria were met for that Parameter, V=Volatiles, S=Semivolatiles, P=PCBs, X=Explosives

q=qualified; t=total number of samples analyzed; a=number of samples affected

SUMMARY

All samples were successfully analyzed for all target compounds according to U.S. EnvironmentalProtection Agency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelinesfor Organic Data Review (October 1999), with Modifications for use within USEPA Region II;along with the Quality Assurance/Quality Control (QA/QC) requirements for the analytical methodsused for the analyses. All instruments and method sensitivities were according to the specifiedanalytical methods. Refer to Minor Problems for information regarding biases identified during datavalidation.

MAJOR PROBLEMS

MINOR PROBLEMS

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USEPA Region II Data ValidationLOOWMCGI/ER081001-6496.wpd Page 8 of 12

Semivolatiles:

PCBs:

Explosives:

NOTES

C Electronic Data Deliverable (EDD): Several rows in an electronic data deliverable (EDD)are marked with an “X” and hidden before printing a data summary form. These rows mayinclude quality control samples such as Method Blanks, Laboratory Control Samples, MatrixSpikes, or Matrix Spike Duplicates which are not validated. Additionally, some field sampleresults may not be used since only one (1) result for each compound is reported aftervalidation. The following list indicates some instances in which an “X” may be placed inthe DVQ column:1. The compounds in an analysis that have exceeded the instrument calibration range.2. All compounds in a diluted analysis that were within the calibration range in the

initial analysis.3. All compounds in either the initial analysis or re-analysis of a sample, depending on

which analysis is not reported on the EDD.Although QC samples and some field samples results may not be used, all data werereviewed and considered in the overall assessment.

C Data Validation Qualifier (DVQ): This refers to the column on the data summary form inwhich EPA Region III and other qualifiers have been placed by the data validator.

C Data Validation Result (DVR): This refers to the column on the data summary form usedto report results that have been modified by the data validator. A result in the DVR columnthat is qualified “U” indicates a modification of the reporting limit. Results in the DVRcolumn supersede those reported by the laboratory.

C Tentatively Identified Compounds (TICs): The TICs, if applicable, were reviewed duringdata validation.

C Compound Quantitation: Positive results for compounds which are below the CRQL werequalified as estimated “J” on the EDD.

C Blank Contaminants: The maximum concentration of all compounds found in the analyses

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USEPA Region II Data ValidationLOOWMCGI/ER081001-6496.wpd Page 9 of 12

of the trip, field or laboratory method blanks are listed in the following table. Associatedsamples with positive results of common laboratory contaminants less than ten times (<10X)the blank concentration, or positive results of other contaminants less than five times (<5X)the blank concentration, found in the associated samples were qualified as “B” on theEDDs.

AnalyticalFraction

Compound MaximumConcentration

Units Blank Type

Volatiles

Carbon Disulfide 2.4 ug/L Trip BlankAcetone* 4.8 ug/L Rinsate Blank

Methylene Chloride* 0.57 ug/L Trip BlankSemivolatiles Naphthalene 0.026 ug/L Rinsate Blank

PCBs NoneExplosives None

*Common lab contaminant

Volatiles

C Calibration: One or more compound(s) failed the percent difference (%D) precision criteria(i.e. %D>25%) in the associated continuing calibrations. No positive results were detectedfor these compound in the samples associated with these calibrations. Since the %RSDand/or %D values did not grossly exceed the QC criteria (i.e. < 50%), no action was taken.

Semivolatiles

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The soil MS/MSD displayed two (2)out of one hundred forty -eight (148) spike recoveries, and one (1) out of seventy four (74)RPDs outside the QC limit. No action was taken.

The aqueous MS/MSD displayed one (1) out of one hundred forty -eight (148) spikerecoveries outside the QC limit. No action was taken.

PCBs:

Explosives:

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USEPA Region II Data ValidationLOOWMCGI/ER081001-6496.wpd Page 10 of 12

“INORGANIC VALIDATION”

The validation was based on the following parameters:

Data Validation Summary

ParametersM Cr+6

q t a q t a* Data Completeness 16 0 2 0

* Holding Time 16 0 2 0

Calibration Verification x 16 13 2 0

Laboratory and Field Blanks analyses x 16 15 2 0

* ICP Interference Check Sample results 16 0 2 0

Matrix Spike recoveries (MS) x 16 13 2 1

* Laboratory and Field Duplicates 16 0 2 0

Laboratory Control Sample(LCS) x 16 3 2 0

Serial Dilution results x 16 13 2 0

* Furnace Atomic Absorption results (FAA) 16 0 2 0

* Analyte Identification 16 0 2 0

* Analyte Quantitation 16 0 2 0* All Criteria were met for that Parameter, M=Metals, Cr+6=Hexavalent Chromium

q=qualified; t=total number of samples analyzed; a=number of samples affected

SUMMARY

All samples were successfully analyzed for all target analytes according to the pertinent parts of U.S.Environmental Protection Agency (USEPA) Contract Laboratory Program (CLP) NationalFunctional Guidelines for Inorganic Data Review (July 2002), with Modifications for use withinUSEPA Region II; along with the Quality Assurance/Quality Control (QA/QC) requirements forthe analytical methods used for the analyses. All instruments and method sensitivities wereaccording to the analytical methods. Refer to Minor Problems for information regarding biasesidentified during data validation.

MAJOR ISSUES

C None noted.

MINOR ISSUES

C Laboratory and Field Blanks analyses: Analytes detected in the laboratory and/orequipment blanks, that affect sample results, with concentration above the instrumentdetection limit (IDL) are listed below. Analytes in the samples with concentration less thanfive (5) times the blank concentration have been reported on the EDDs and qualified “B”.

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USEPA Region II Data ValidationLOOWMCGI/ER081001-6496.wpd Page 11 of 12

Analyte Blank TypeB RBCu PBPb CCBTh ICB, CCBHg ICB, CCB, PB, RB

PB = Preparation BlankICB = Initial Calibration BlankCCB = Continuing Calibration Blank RB = Rinse Blank

C Calibration:The soil Contract Required Detection Limits (CRDL) displayed high recovery(i.e., >110%) for Th analyte. Positive results less than 2x CRDL may be biased high andwere qualified “J”, unless superseded by the “B” qualifier.

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The soil MS/MSD displayed lowrecoveries (i.e., <75%, but >30%) for Sb analyte. Quantitation limits maybe biased low andwere qualified “UJ”.

The soil MS/MSD displayed high recoveries (i.e., >125%) for Mg, Mn & K analytes.Positive results maybe biased high and were qualified “J”.

C Laboratory Control Sample (LCS): The aqueous LCS displayed low recovery for the Sb(i.e., <75%) analyte. Quantitation limits maybe biased low and were qualified “UJ”.

C Serial Dilution: The Zn analyte displayed a percent difference (%D) greater than 10% inthe soil samples. Positive results may be estimated and were qualified “J”.

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The soil MS/MSD, associated withsample C2-OCY-SO-S02-7, displayed low recoveries (i.e., <85%, but >30%) for HexavalentChromium. Quantitation limits maybe biased low and were qualified “UJ”.

NOTES

C Calibration: The Contract Required Detection Limits (CRDL) displayed low recovery (i.e.,<90%) for Ca. All positive results were greater than 2x the CRDL. No data were qualified.

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The soil MS/MSD recoveries displayedrecoveries outside the QC limits for Al Ca, & Fe analytes. However, the sampleconcentration for these analytes were greater than 4x the spike concentration. No action wastaken.

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The aqueous MS/MSD recoveriesdisplayed recoveries outside the QC limits for Mg & Na analytes. However, the sampleconcentration for these analytes were greater than 4x the spike concentration. No action wastaken.

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USEPA Region II Data ValidationLOOWMCGI/ER081001-6496.wpd Page 12 of 12

REPORT CONTENT STATEMENT

All data for this project were reviewed in accordance with the pertinent parts of the U.S.Environmental Protection Agency (USEPA) Contract Laboratory Program (CLP) NationalFunctional Guidelines for Organic Data Review (October 1999) and for Inorganic Data Review (July2002), with Modifications for use within USEPA Region II; along with the QualityAssurance/Quality Control (QA/QC) requirements for the analytical methods used for the analyses.The text of the report addresses only those problems affecting data usability.

ATTACHMENTS

l ) Glossary of Data Qualifiers2) Electronic Data Deliverable (EDD). These include:

(a) All results for target compounds with qualifier codes where applicable.(b) All unusable detection limits (qualified “R”), where applicable.

3) Electronic Data Package (.pdf file) as Support Documentation

DCN: ER091001-6496

Respectfully Submitted,

Date: October 09, 2010

QA/Review:

Page 50: Appendix G Data Usability Summary Report

MCGI

USEPA Region IIVolatiles, Explosives, Metals, Hexavalent Chromium & Radiological

Data Validation Report

LOOWOccidental Property

TestAmerica Lab Report # C0H280409MCGI Project No. ER081001-8409

Prepared for:

Earth Resources Technology, Inc.Laurel, MD

Prepared by:“MCGI”

Meridian Consultant Group, Inc.Environmental Services & Data Validation

1997 Annapolis Exchange Pkwy, Suite 300Annapolis, MD 21401

Phone:(301)803-9207 Fax:(410)972-4701

www.meridiancgi.com

October 2010

Page 51: Appendix G Data Usability Summary Report

CONTENTS

C GLOSSARY OF ACRONYMS & TERMS

C COMMUNICATION RECORDS

C GLOSSARY OF DATA VALIDATION QUALIFIERS

C DATA VALIDATION REPORT NARRATIVE

C ELECTRONIC DATA DELIVERABLE (EDD) with applicable qualifiers, Refer to the EDD Excel file.

C SUPPORT DOCUMENTATION, Refer to the electronic Data Package PDF file.

Page 52: Appendix G Data Usability Summary Report

GLOSSARY OF ACRONYMS & TERMS

Page 53: Appendix G Data Usability Summary Report

GLOSSARY OF ACRONYMS & TERMS

One or more of the following acronyms and terms may have been used in the descriptive process of the OrganicData Validation.

Acronyms:BFB Bromofluorobenzene (volatile instrument performance check)BNA Base/Neutral/AcidCARD CLP Analytical Results DatabaseCCCs Calibration Check CompoundsCCS Contract Compliance ScreeningCF Calibration FactorCLP Contract Laboratory ProgramCOC Chain of CustodyCRQL Contract Required Quantitation LimitCSF Complete SDG File%D Percent DifferenceDAS Delivery of Analytical ServicesDCB Decachlorobiphenyl (Pesticide/PCB/ surrogate compound)DFTPP Decafluorotriphenylphosphine (semivolatile instrument performance check)DSF Data Summary FormECD Electron-Capture DetectorEICP Extended Ion Current ProfileEMSL-LV Environmental Monitoring Support Laboratory - Las VegasEPA United States Environmental Protection AgencyGC Gas ChromatographyGC/EC Gas Chromatography/Electron CaptureGC/MS Gas Chromatography/Mass SpectraGPC Gel Permeation Chromatography (Clean Up)ICAL Initial CalibrationIS Internal StandardLCS Laboratory Control SampleLCL Lower Control LimitMCL Maximum Contamination LevelMDL Method Detection LimitMS/MSD Matrix Spike/Matrix Spike Duplicatem/z The ratio of mass (m) to charge (z) of ions measured by GC/MSOADS Organic Analysis Data Sheet (Form 1)ORDA Organic Regional Data AssessmentPCB Poly Chlorinated BiphenylPEM Performance Evaluation MixturePRP Potential Responsible Party

-i-

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QA/QC Quality Assurance/Quality ControlQAPjP Quality Assurance Project PlanQC Quality Control%R Percent Recovery of spiked amountRAS Routine Analytical ServicesRF Response FactorRIC Reconstructed Ion ChromatogramRPD Relative Percent DifferenceRRF Relative Response FactorRSD Relative Standard DeviationRT Retention TimeRTW Retention Time WindowSDG Sample Delivery GroupSMC System Monitoring CompoundSMO Sample Management OfficeSOP Standard Operation ProceduresSOW Statement of WorkSPCCs System Performance Check CompoundsSSL Samples Shipping LogSVOA Semivolatile Organic AnalyteTCL Target Compound ListTCX Tetrachloro-m-Xylene (Pesticide/PCB surrogate compound)TIC Tentatively Identified CompoundTPH Total Petroleum HydrocarbonsTR Traffic ReportUCL Upper Control LimitVOA Volatile Organic AnalyteVTSR Validated Time of Sample Receipt

Terms:

Associated SamplesAny sample related to a particular QC analysis.

Case A finite, usually predetermined number of samples collected over a given time period for a particularsite. A Case consists of one or more Sample Delivery Group(s).

Contract Compliance Screening (CCS)A process in which the SMO inspects the data for contractual compliance and provides EMSL-LVlaboratories and the Regions with their findings.

-ii-

Page 55: Appendix G Data Usability Summary Report

Contractual Holding TimeThe time from VTSR (validated time of sample receipt) to laboratory extraction and /or analysis.

Data Validation Qualifier (DVQ)This refers to the column on the data summary form in which EPA Region III and other qualifiers have beenplaced by the data validator.

Data Validation Result (DVR)This refers to the column on the data summary form used to report results that have been modified by thedata validator. A result in the DVR column that is qualified “U” indicates a modification of the reportinglimit.

Field Blank Field blanks are intended to identify contaminants that may have been introduced in the field.Examples are rinsate blank (RB), field blanks (FB) and trip blank (TB).

Field DuplicateA duplicate sample generated in the field; not in the laboratory.

Initial Calibration (ICAL)The establishment of a calibration curve with the appropriate number of standards and concentrationranges. The calibration curve plots absorbances and/or emissions versus concentration of thestandards. .

Matrix Spike/Matrix Spike Duplicate (MS/MSD)Introduction of a known concentration of a compound into a sample to provide information aboutthe effect of sample matrix on the extraction and/or measurement methodology.

Performance Evaluation MixtureA standard used to verify that the ICAL sequence is stable throughout the GC or GC/MS analyses.

Sample Delivery Group (SDG)Defined by one of the following, whichever occurs first:- case of sample- each twenty field samples in a case or- each 14-day calendar period during which field samples in a case are received, beginning with thereceipt of the first sample in the SDG.

Technical Holding TimeThe time from sample collection to laboratory extraction and /or analysis

-iii-

Page 56: Appendix G Data Usability Summary Report

GLOSSARY OF ACRONYMS & TERMS

One or more of the following acronyms and terms may have been used in the descriptive process of the InorganicData Validation.

Acronyms:AA Atomic AbsorptionCARD CLP Analytical Results DatabaseCCB Continuing Calibration BlankCCS Contract Compliance ScreeningCCV Continuing Calibration VerificationCF Calibration FactorCLP Contract Laboratory ProgramCOC Chain of CustodyCRDL Contract Required Detection LimitCSF Complete SDG FileCV Cold Vapor%D Percent DifferenceDAS Delivery of Analytical ServicesDSF Data Summary FormEMSL-LV Environmental Monitoring Support Laboratory - Las VegasEPA United States Environmental Protection AgencyICAL Initial CalibrationICB Initial Calibration BlankICP Inductively Coupled PlasmaICS Interference Check SampleICV Initial Calibration VerificationIDL Instrument Detection LimitIRDA Inorganic Regional Data AssessmentLCS Laboratory Control SampleLCL Lower Control LimitMCL Maximum Contamination LevelMDC Minimum Detectable ConcentrationMDL Method Detection LimitMS/MSD Matrix Spike/Matrix Spike DuplicateMSA Method of Standard AdditionPB Preparation BlankPCB Poly Chlorinated BiphenylPRP Potential Responsible PartyQA/QC Quality Assurance/Quality ControlQAPjP Quality Assurance Project PlanQC Quality Control

-i-

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%R Percent Recovery of spiked amountRAS Routine Analytical ServicesRPD Relative Percent DifferenceRRF Relative Response FactorRSD Relative Standard DeviationSDG Sample Delivery GroupSMO Sample Management OfficeSOP Standard Operation ProceduresSOW Statement of WorkSSL Samples Shipping LogTAL Target Analyte ListTR Traffic ReportUCL Upper Control LimitVTSR Validated Time of Sample Receipt

Terms:

Associated SamplesAny sample related to a particular QC analysis. For Example: - For ICV, all samples run under the same calibration curve.- For duplicate RPD, all SDG samples digested/distilled of the same matrix.

Case A finite, usually predetermined number of samples collected over a given time period for a particularsite. A Case consists of one or more Sample Delivery Group(s).

Continuing Calibration Blank (CCB)A deionized water sample run every ten (10) samples designed to detect any carryovercontamination.

Continuing Calibration Verification (CCV)A deionized water sample run every ten (10) samples designed to detect any carryovercontamination.

Contract Compliance Screening (CCS)A process in which the SMO inspects the data for contractual compliance and provides EMSL-LVlaboratories and the Regions with their findings.

Contractual Holding TimeThe time from VTSR (validated time of sample receipt) to laboratory extraction and /or analysis.

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Data Validation Qualifier (DVQ)This refers to the column on the data summary form in which EPA Region III and otherqualifiers have been placed by the data validator.

Data Validation Result (DVR)This refers to the column on the data summary form used to report results that have beenmodified by the data validator. A result in the DVR column that is qualified “U” indicatesa modification of the reporting limit.

Field Blank Field blanks are intended to identify contaminants that may have been introduced in the field.Examples are rinsate blank (RB), field blanks (FB) and trip blank (TB).

Field DuplicateA duplicate sample generated in the field; not in the laboratory.

Initial Calibration (ICAL)The establishment of a calibration curve with the appropriate number of standards and concentrationranges. The calibration curve plots absorbancies and/or emissions versus concentration of thestandards.

.Initial Calibration Blank (ICB)

First blank run after the calibration curve .

Initial Calibration Verification (ICV)First standard run after the calibration curve .

Matrix Spike/Matrix Spike Duplicate (MS/MSD)Introduction of a known concentration of a compound into a sample to provide information aboutthe effect of sample matrix on the extraction and/or measurement methodology.

Post Digestion SpikeThe addition of known amount of standard after digestion. (Also identified as analytical spike, orspike, for furnace analyses.)

Preparation Blank (PB)Blank taken through the digestion process to detect internal laboratory contamination.

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Sample Delivery Group (SDG)Defined by one of the following, whichever occurs first:- case of sample- each twenty field samples in a case or- each 14-day calendar period during which field samples in a case are received, beginning with thereceipt of the first sample in the SDG.

Serial DilutionA sample run at a specific dilution to determine whether any significant chemical or physicalinterferences exist due to sample matrix effect, for ICP only.

Technical Holding Time

The time from sample collection to laboratory extraction and /or analysis.

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COMMUNICATION RECORDS

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“N/A”

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GLOSSARY OF DATA VALIDATION QUALIFIERS

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GLOSSARY OF DATA QUALIFIER CODES (ORGANIC)

CODES RELATED TO IDENTIFICATION:(Confidence concerning presence or absence of compounds)

U = Not detected above the level of the associated value. The associated value is eitherthe approximate sample quantitation or detection limit.

NO CODE = Confirmed identification

B = Not detected substantially above the level reported in laboratory or field blanks.

R = Unusable results. Analyte may or may not be present in the sample.

N = Tentative identification. Consider present. Special methods may be needed toconfirm its presence or absence in future sampling efforts.

CODES RELATED TO QUANTITATION:(Can be used for both positive results and sample quantitation limits)

J = Analyte present. Reported value may not be accurate or precise (estimated value).

K = Analyte present. Reported value may be biased high. Actual value is expected to belower.

L = Analyte present. Reported value may be biased low. Actual value is expected to behigher.

UJ = Not detected. Quantitation limit may be inaccurate or imprecise.

UL = Not detected. Quantitation limit is probably higher.

OTHER CODES:

NJ = Qualitative identification questionable. Presumptively present at approximatequantity.

Q = No analytical result.

X =Data not Validated.

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GLOSSARY OF DATA QUALIFIER CODES (INORGANIC)

CODES RELATED TO IDENTIFICATION:(Confidence concerning presence or absence of analytes).

U = Not detected above the level of the associated value. The associated value is eitherthe approximate sample quantitation or detection limit.

NO CODE = Confirmed identification

B = Not detected substantially above the level reported in laboratory or field blanks.

R = Unusable results. Analyte may or may not be present in the sample.

N = Tentative identification. Consider present. Special methods may be needed toconfirm its presence or absence in future sampling efforts.

CODES RELATED TO QUANTITATION:(Can be used for both positive results and sample detection limits)

J = Analyte present. Reported value may not be accurate or precise (estimated value).

K = Analyte present. Reported value may be biased high. Actual value is expected to belower.

L = Analyte present. Reported value may be biased low. Actual value is expected to behigher.

UJ = Not detected. Quantitation limit may be inaccurate or impresice.

UL = Not detected. Quantitation limit is probably higher.

OTHER CODES:

NJ = Qualitative identification questionable. Presumptively present at approximatequantity.

Q = No analytical Result.X = Data not validated.

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DATA VALIDATION REPORT NARRATIVE

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USEPA Region II Data ValidationLOOWMCGI/ER081001-8409.wpd Page 5 of 12

.MCGI

Meridian Consultant Group, Inc. (301)803-9207 Phone

Environmental Services & Data Validation (410)972-4701 Fax

1997 Annapolis Exchange Pkwy., Suite 300 www.meridiancgi.com Annapolis, MD 21401

DATE: October 14, 2010

SUBJECT: USEPA Region II Organic & Inorganic Data Validation ReportVolatiles, Explosives, Metals, Hexavalent Chromium & RadiologicalTestAmerica Lab SDG No. C0H280409Site: LOOW, Occidental PropertyMSTI Project No. ER081001-8409

FROM:

Meridian Consultant Group, Inc.

TO:Earth Resources Technology, Inc.

OVERVIEW

This Sample Delivery Group (SDG) consisted of twenty (20) soil & two (2) aqueous samples submitted toTestAmerica Laboratories, Pittsburgh, PA, for Volatiles, Explosives, Metals, Hexavalent Chromium &Radiological analyses according to SW-846, Method 8260B, 8330, 6020A & 7196A, respectively, the analyticalmethodologies for the Radiological analyses are listed in the Radiological section of the report. The Explosives,Metals and Radiological analyses were subcontracted to TestAmerica, St. Louis Laboratory. The sample setincluded one (1) trip blank, analyzed for volatiles only, one (1) rinsate blank, and two (2) soil field duplicatepairs. The samples were analyzed in accordance with the Chain-of-Custody (COC), see Sample IdentificationSummary.

Sample Identification Summary

SAMPLE INFORMATION Analysis

Field ID Lab ID Matrix V X M Cr R

C2-OXY-SO-P21-1 C0H280409001 Soil x x xC2-OXY-SO-P21-3 C0H280409002 Soil x x xC2-OXY-SO-P22-2 C0H280409003 Soil x x xC2-OXY-SO-P22-3 C0H280409004 Soil x x xC2-OXY-SO-P23-1 C0H280409005 Soil x x x

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SAMPLE INFORMATION Analysis

Field ID Lab ID Matrix V X M Cr R

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C2-OXY-SO-P23-3 C0H280409006 Soil x x xC2-OXY-SO-P24-1 C0H280409007 Soil x x xC2-OXY-SO-P24-3 C0H280409008 Soil x x xC2-OXY-SO-DUPE1 C0H280409009 Soil x x xC2-OXY-SO-SOE-1 C0H280409010 Soil x x xC2-OXY-SO-SOE-3 C0H280409011 Soil x x xC2-OXY-SO-SIN-1 C0H280409012 Soil x x xC2-OXY-SO-SIN-3 C0H280409013 Soil x x xC2-OXY-SO-SIS-1 C0H280409014 Soil x x xC2-OXY-SO-SIS-3 C0H280409015 Soil x x xC2-OXY-SO-SIW-1 C0H280409016 Soil x x xC2-OXY-SO-SIW-3 C0H280409017 Soil x x xC2-OXY-SO-Y20 C0H280409018 Soil xC2-OXY-RB-1 C0H280409019 Aqueous x x xC2-OXY-DET-0.5 C0H280409020 Soil x x xC2-OXY-DET-1 C0H280409021 Soil x x xC2-OXY-SO-P2-03-DUP C0H280409022 Soil x x xTB C0H280409023 Aqueous x

V=Volatiles, X=Explosives. M=Metals, Cr=Hexavalent Chromium, R=Radiological

The Organic analytical results were validated according to the pertinent parts of U.S. Environmental ProtectionAgency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelines for Organic Data Review(October 1999), with Modifications for use within USEPA Region II according to USEPA Region II SOPHW-24, Revision 2, August 2008: Validating Volatile Organic Compounds by SW-846 Method 8260B(USEPA, 2008), and USEPA Region II SOP No. HW-16, Revision 2, September 2006: Nitroaromatics andNitroamines by HPLC (USEPA, 2006c); along with the Quality Assurance/Quality Control (QA/QC)requirements for the analytical methods used for the analyses.

The Inorganic analytical results were validated according to the pertinent parts of U.S. Environmental ProtectionAgency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelines for Inorganic DataReview (July 2002), with Modifications for use within USEPA Region II according to USEPA Region II SOPNo. HW-2, Revision 13, September 2006, Evaluation of Metals Data for the CLP Program (USEPA, 2006b);along with the Quality Assurance/Quality Control (QA/QC) requirements for the analytical methods used forthe analyses.

The Radiological analytical results were validated according to the pertinent parts of U.S. EnvironmentalProtection Agency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelines for InorganicData Review (July 2002); along with the Quality Assurance/Quality Control (QA/QC) requirements for theanalytical methods used for the analyses.

Please note that the “B” qualifier was used instead of the “U” qualifier, as per USEPA Region II, to point outclearly those compounds qualified due to blank contamination.

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“ORGANIC VALIDATION”

The validation was based on the following parameters:

Data Validation Summary

ParametersV X

q t a q t a

* Data Completeness 1 0 21 0

* Holding Time 1 0 21 0

* Calibrations 1 0 21 0

* Laboratory and Field Blanks analyses 1 0 21 0

Surrogate Recoveries 1 0 x 21 1

* Matrix Spike/Matrix Spike Duplicate 1 0 21 0

* Laboratory Control Sample(LCS) 1 0 21 0

* Laboratory and/or Field Duplicates 1 0 21 0

* Internal Standards 1 0 21 0

* Pesticide Instrument Performance 1 0 21 0

* Sample Cleanup 1 0 21 0

Compound Identification 1 0 x 21 12

Compound Quantitation 1 0 x 21 8

* Sample Preservation 1 0 21 0

* All Criteria were met for that Parameter, V=Volatiles, X=Explosives

q=qualified; t=total number of samples analyzed; a=number of samples affected

SUMMARY

All samples were successfully analyzed for all target compounds according to U.S. Environmental ProtectionAgency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelines for Organic Data Review(October 1999), with Modifications for use within USEPA Region II; along with the QualityAssurance/Quality Control (QA/QC) requirements for the analytical methods used for the analyses. Allinstruments and method sensitivities were according to the specified analytical methods. Refer to MinorProblems for information regarding biases identified during data validation.

MAJOR PROBLEMS

MINOR PROBLEMS

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Explosives:

NOTES

C Electronic Data Deliverable (EDD): Several rows in an electronic data deliverable (EDD) are markedwith an “X” and hidden before printing a data summary form. These rows may include quality controlsamples such as Method Blanks, Laboratory Control Samples, Matrix Spikes, or Matrix SpikeDuplicates which are not validated. Additionally, some field sample results may not be used since onlyone (1) result for each compound is reported after validation. The following list indicates someinstances in which an “X” may be placed in the DVQ column:1. The compounds in an analysis that have exceeded the instrument calibration range.2. All compounds in a diluted analysis that were within the calibration range in the initial analysis.3. All compounds in either the initial analysis or re-analysis of a sample, depending on which

analysis is not reported on the EDD.Although QC samples and some field samples results may not be used, all data were reviewed andconsidered in the overall assessment.

C Data Validation Qualifier (DVQ): This refers to the column on the data summary form in which EPARegion III and other qualifiers have been placed by the data validator.

C Data Validation Result (DVR): This refers to the column on the data summary form used to reportresults that have been modified by the data validator. A result in the DVR column that is qualified “U”indicates a modification of the reporting limit. Results in the DVR column supersede those reported bythe laboratory.

C Tentatively Identified Compounds (TICs): The TICs, if applicable, were reviewed during datavalidation.

C Compound Quantitation: Positive results for compounds which are below the CRQL were qualifiedas estimated “J” on the EDD.

C Blank Contaminants: The maximum concentration of all compounds found in the analyses of the trip,field or laboratory method blanks are listed in the following table. Associated samples with positiveresults of common laboratory contaminants less than ten times (<10X) the blank concentration, orpositive results of other contaminants less than five times (<5X) the blank concentration, found in the

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associated samples were qualified as “B” on the EDDs.

AnalyticalFraction

Compound MaximumConcentration

Units Blank Type

Volatile Carbon Disulfide 1.5 ug/L Trip BlankExplosives None

*Common lab contaminant

Volatiles

C Calibration: One or more compound(s) failed the percent difference (%D) precision criteria (i.e.%D>25%) in the associated continuing calibrations. No positive results were detected for thesecompound in the samples associated with these calibrations. Since the %RSD and/or %D values didnot grossly exceed the QC criteria (i.e. < 50%), no action was taken.

Explosives:

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The MS/MSD of C2-OXY-SO-P24-1 and C2-OXY-SO-P24-3 displayed one (1), each, out of twenty-eight (28) spike recoveries above the QC limitdue to high concentration in the native sample. No action was taken.

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“INORGANIC VALIDATION”

The validation was based on the following parameters:

Data Validation Summary

ParametersM Cr+6

q t a q t a* Data Completeness 21 0 21 0

* Holding Time 21 0 21 0

Calibration Verification x 21 20 21 0

Laboratory and Field Blanks analyses x 21 7 21 0

* ICP Interference Check Sample results 21 0 21 0

Matrix Spike recoveries (MS) x 21 21 x 21 20

* Laboratory and Field Duplicates 21 0 21 0

Laboratory Control Sample(LCS) x 21 20 21 0

Serial Dilution results x 21 20 21 0

* Furnace Atomic Absorption results (FAA) 21 0 21 0

* Analyte Identification 21 0 21 0

* Analyte Quantitation 21 0 21 0* All Criteria were met for that Parameter, M=Metals, Cr+6=Hexavalent Chromium

q=qualified; t=total number of samples analyzed; a=number of samples affected

SUMMARY

All samples were successfully analyzed for all target analytes according to the pertinent parts of U.S.Environmental Protection Agency (USEPA) Contract Laboratory Program (CLP) National FunctionalGuidelines for Inorganic Data Review (July 2002), with Modifications for use within USEPA Region II; alongwith the Quality Assurance/Quality Control (QA/QC) requirements for the analytical methods used for theanalyses. All instruments and method sensitivities were according to the analytical methods. Refer to MinorProblems for information regarding biases identified during data validation.

MAJOR ISSUES

C None noted.

MINOR ISSUES

C Laboratory and Field Blanks analyses: Analytes detected in the laboratory and/or equipment blanks,that affect sample results, with concentration above the instrument detection limit (IDL) are listedbelow. Analytes in the samples with concentration less than five (5) times the blank concentration havebeen reported on the EDDs and qualified “B”.

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Analyte Blank TypeB CCB, PBTl CCB, PBHg ICB, PB

PB = Preparation BlankICB = Initial Calibration BlankCCB = Continuing Calibration Blank RB = Rinse Blank

C Calibration: The soil Contract Required Detection Limits (CRDL) displayed high recovery (i.e.,>110%) for Ca, Ni and Zn analytes. Positive results less than 2x CRDL may be biased high and werequalified “J”, unless superseded by the “B” qualifier.

The soil Contract Required Detection Limits (CRDL) displayed low recovery (i.e., <90%) for Na andB analyte. Positive results less than 2x CRDL and quantitation limits may be biased high and werequalified “J”&”UJ”, respectively, unless superseded by the “B” qualifier.

Boron displayed high recoveries in the associated CCV. Positive results were qualified “J”.

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The soil MS/MSD displayed low recoveries (i.e.,<75%, but >30%) for Sb analyte. Positive results and quantitation limits maybe biased low and werequalified “J” & “UJ”, respectively.

The soil MS/MSD displayed high recoveries (i.e., >125%) for Ba, Be, Mg, Mn, K, Li, Se & Znanalytes. Positive results maybe biased high and were qualified “J”.

C Laboratory Control Sample (LCS): The soil LCS displayed high recovery (i.e., >125%) for B analyte.Positive results maybe biased high and were qualified “J”.

C Serial Dilution: The Ca analyte displayed a percent difference (%D) greater than 10% in the soilsamples. Positive results may be estimated and were qualified “J”.

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The Hexavalent Chromium MS/MSD displayedlow recoveries outside the QC limits. The samples were redigested and reanalyzed with similar resultsfor the MS/MSD. Positive results and quantitation limits maybe biased low and were qualified “J” &“UJ”, respectively.

NOTES

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The aqueous MS/MSD recoveries displayedrecoveries outside the QC limits for Mg analyte. However, the sample concentration for this analytewas greater than 4x the spike concentration. No action was taken.

C Matrix Spike/Matrix spike Duplicate (MS/MSD): The soil MS/MSD recoveries displayed recoveriesoutside the QC limits for Al &Fe analytes. However, the sample concentration for these analytes weregreater than 4x the spike concentration. No action was taken.

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“RADIOLOGICAL VALIDATION”

One samples “C2-OXY-SO-Y20" was analyzed for Gross Alpha/Beta - Method 9310M; Plutonium, Thorium& Uranium - A-01-R MOD; Radium - GA-01-R MOD; and Strontium - SR-03-RC MOD.

The Radiological analytical results were validated according to the pertinent parts of U.S. EnvironmentalProtection Agency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelines for InorganicData Review (July 2002); along with the Quality Assurance/Quality Control (QA/QC) requirements for theanalytical methods used for the analyses.

No data were qualified during the validation for this sample.

REPORT CONTENT STATEMENT

All data for this project were reviewed in accordance with the pertinent parts of the U.S. EnvironmentalProtection Agency (USEPA) Contract Laboratory Program (CLP) National Functional Guidelines for OrganicData Review (October 1999) and for Inorganic Data Review (July 2002), with Modifications for use withinUSEPA Region II; along with the Quality Assurance/Quality Control (QA/QC) requirements for the analyticalmethods used for the analyses. The text of the report addresses only those problems affecting data usability.

ATTACHMENTS

l ) Glossary of Data Qualifiers2) Electronic Data Deliverable (EDD). These include:

(a) All results for target compounds with qualifier codes where applicable.(b) All unusable detection limits (qualified “R”), where applicable.

3) Electronic Data Package (.pdf file) as Support Documentation

DCN: ER081001-8409

Respectfully Submitted,

Date: October 14, 2010

QA/Review:

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